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Inmarsat Global Limited 99 City Road London EC1Y 1AX United Kingdom 24th May 2018 Mr. Alo Einla – Head of Frequency Management Department Estonian Technical Surveillance Authority (TJA) Söle 23A 10614 Tallinn Estonia Subject: The use of Ka-band In-flight Connectivity (IFC) onboard aircraft whilst at airports in Estonia Dear Mr. Einla, Following guidance from ICAO, who have developed guidelines for the Expanded Use of Portable Electronic Devices (Cir 340 Link) and leading Aviation Authorities, including the FAA (InFO 13010 Link) and EASA (SIB No: 2013-21 Link), many airlines now permit passengers to use their Portable Electronic Devices (PEDs), such as smart phones and tablets, during all phases of flight (doors closed to doors open), provided that the device is in ‘flight’ or ‘airplane’ mode. Consequently, there has been a significant global increase in passenger demand for data In-flight Connectivity (IFC) throughout all phases of flight, including after boarding and until disembarkation, a service commonly known as Gate-to-Gate (G2G) connectivity. Continued projected IFC demand has resulted in many airlines placing a high importance on the ability to provide G2G connectivity as a fundamental component of their passenger experience and increasingly a factor in a consumer’s airline choice when booking a flight. With the time spent on the ground with “Doors Closed” being a potentially considerable percentage of the total “flight time”, the ability to operate G2G connectivity is vital. Any restrictions may result in the non-viability of the overall service. Our G2G solution, powered by the Global Xpress (GX) FSS satellite constellation, operating in Ka-band, has been designed in a way that Wi-Fi can be available in the cabin during all phases of flight to PEDs, as long as in ‘flight’ or ‘airplane’ mode. Termination of Wi-Fi provision would be based on an aircraft’s status at the gate (e.g. “Door Open”). GX IFC services are already being provided on the ground to the passengers of several airlines (including Lufthansa and Qatar Airways), in an ever increasing number of countries. Therefore we are writing to seek your non-objection to the operation of aircraft mounted Ka-band GX terminals, for the provision of IFC services whilst on the ground at airports in Estonia. Usage would be limited to passengers only as per the aforementioned guidance. Page 1 of 2 As you may be aware, technical and operational conditions for terminals like GX (i.e. Earth Stations in Motion - ESIMs) transmitting in the 29.5-30GHz band are fully covered under Resolution 156 (WRC-15) and ITU RR 5.527A. These conditions further mitigate any risk of harmful interference to other systems operating in the same band. A recent report (ECC Report 272) by the CEPT’s Electronic Communications Committee on the safety of satellite earth station terminals at airports, was approved in January 2018 (Link). The studies contained within the report concluded that there would be no impact to aeronautical safety through the use of Ka-band satellite terminals when on the ground, operating at a maximum EIRP of 58.4dBW. Consequently, it is recommended that there should be no restrictions on the operation of earth stations complying with those EIRP limits in the proximity of or within airfields. Inmarsat can confirm that GX terminals operate well below these EIRP limits (currently at ~46dBW) and are therefore safe under the terms of ECC Report 272 for operation within airfields. These aforementioned regulatory changes and studies have resulted in an increasing number of countries embracing and facilitating G2G connectivity. These include (but not limited to):  Australia  Norway  Brazil  Qatar  Canada  Singapore  Croatia  Sweden  Denmark  United Arab Emirates  Iceland  United Kingdom  New Zealand  United States With consideration of the above, we hope that the TJA can confirm their non- objection to the operation of aircraft mounted Ka-band GX user terminals whilst on the ground at airports in Estonia, to the benefit of the Estonian community. Please do not hesitate to contact me if you would like any further information regarding any of the above. Yours faithfully, Chris Horton Market Access and Regulatory Affairs Officer [email protected] Tere Palun registreeri see CEPT kirjavahetuse alla ja saada mulle täitmiseks. Alo From: Chris Horton [mailto:[email protected]] Sent: Thursday, May 24, 2018 9:45 AM To: Alo Einla <[email protected]> Subject: Inmarsat Gate to Gate Request Dear Mr. Einla, As an introduction, my name is Chris Horton and I am a member of Inmarsat’s regulatory team. Please allow me to contact you directly, to request the TJA’s non-objection to the use of Ka-band for In-flight Connectivity (IFC) onboard aircraft whilst at airports in Estonia. The request letter is attached and I look forward to receiving your feedback. In the meantime, I remain available to provide you with any further information/clarification, if required. Kind regards, Chris Chris Horton Market Access and Regulatory Affairs Festival Tower, Unit 2303 Dubai Festival City P. O. Box 27313 Dubai - UAE T +971 (0) 4 2219200 F +971 (0) 4 2219500 M +971 (0) 56 5067388 E [email protected] W inmarsat.com _____________________________________________________________________ This e-mail has been scanned for viruses by Verizon Business Internet Managed Scanning Services - powered by MessageLabs.